Two data sheets lie on your desk. One supplier states 5 kg CO2 per unit for its component, the other 3 kg for a comparable one. The difference is not in the product. It is in where each of them stopped counting: one at the factory gate, the other already at the raw material.
Almost everything about putting a carbon footprint into a Digital Product Passport hangs on that. There are seven established methods, all of them supported by serious certifiers and associations, and which one the ESPR requires depends on the product. This article explains how the methods differ, which one your product group needs and what you should request today.
How far does the counting go?
A CO2 balance is meaningless without saying how far the counting went. Specialists call this the system boundary. “Product X has a footprint of 5 kg CO2eq” is a statement without it.
Five kilograms, measured up to where?
The three established boundaries:
- To the factory gate (cradle-to-gate) - from raw-material extraction to the manufacturer’s gate. Transport to retail, sale, use and disposal do not count.
- To the grave (cradle-to-grave) - from cradle to grave. Use and disposal count.
- Into the next product (cradle-to-cradle) - to the grave plus the reuse of the material in the next product.
The EU Batteries Regulation requires counting over the whole lifecycle. The ESPR is expected to count to the grave depending on the product category (the draft for textiles shows this).
ISO 14040/14044: the framework of every life-cycle assessment
ISO 14040 and 14044 are the standard for the life-cycle assessment (LCA). They say how you set up an assessment, but not which rules apply to a particular product.
The logic:
- goal definition and system boundary
- inventory analysis (input-output analysis: material and energy flows)
- impact assessment (conversion into CO2eq, water consumption, etc.)
- interpretation and sensitivity
Calculated by an accredited life-cycle consultancy, an ISO-compliant study for a product typically costs 10,000 to 50,000 euros. The calculation is valid for 3 to 5 years, after which it has to be updated.
PEF: the EU’s calculation method
With the Product Environmental Footprint (PEF) the EU has developed a calculation method of its own so that everyone counts the same way. PEF builds on ISO 14040/44 but settles many decisions:
- 16 impact categories (not only climate, but also water, resource use, acidification, etc.)
- defined calculation rules
- defaults for data gaps
For many product categories there are product rules on top (PEFCR, Product Environmental Footprint Category Rules). They are the “sheet music” for PEF: the refinement for the respective product category. As of 2026 such rules exist for leather, batteries, paints, dairy products and a few more; textiles and packaging are in development.
The ESPR builds on PEF. Anyone commissioning a carbon-footprint calculation today should ask the consulting firm whether it delivers PEF-ready.
EPD: the construction industry’s environmental declaration
The environmental declaration (Environmental Product Declaration, EPD, ISO 14025) is the usual form in the construction industry. It is a life-cycle assessment too, calculated to EN 15804, the standard for construction products.
EPDs are issued by national programme operators - in Germany for example IBU, in Switzerland KBOB. Per product an EPD costs similar to a full PEF study, but the infrastructure is more established. Almost every manufacturer of cement, steel and wood already has EPDs.
The new Construction Products Regulation (EU) 2024/3110 does not, however, make the EPD mandatory. The operative text works with the environmental essential characteristics of Annex II, declared over the life cycle and calculated with software the Commission provides free of charge (Art. 15(2)); EN 15804 appears only in the recitals, as the source of characterisation factors for that software. For building-material manufacturers: the EPD will not disappear, but it is the stock of data, not the duty.
To the factory gate in practice: finding the big items
If you do not aim for the full programme but pragmatically count to the factory gate, that takes considerably less effort. The big items are usually the same:
- steel: approx. 1.85 kg CO2eq per kg (primary steel), 0.3 to 0.5 kg (electric arc from scrap)
- aluminium: approx. 12 kg CO2eq per kg (primary), 0.5 kg (recycled)
- cement: 0.8 kg CO2eq per kg
- cotton: 10 to 30 kg CO2eq per kg textile unit, depending on origin and cultivation
- polyester: 3.5 to 6 kg CO2eq per kg
These values come from pooled databases such as ecoinvent. For a first estimate a multiplication is enough: material weights times the CO2 factor from the database. For mandatory reporting that is not enough, but it helps to make internal decisions.
Which values must the DPP show?
Depending on the product category:
- batteries: CO2eq per kWh of battery capacity over the entire lifecycle
- construction products: the environmental essential characteristics of Annex II, declared over the life cycle
- textiles (draft): PEF value per kilogram of textile product
The unit matters. CO2 per item is usually not comparable, because product sizes vary. That is why it is always calculated per reference quantity - kg, m², kWh.
The most common mistake: requesting supplier data too late
The balance of an end product is built 70 to 85 per cent from supplier emissions. If your supplier has no life-cycle data, your end product has none either. Ask your top 10 suppliers for Scope 1 and Scope 2 emission data now, not six months before the ESPR deadline.
The typical lead time to data provision in a B2B relationship is 9 to 18 months.
The three tiers of the Greenhouse Gas Protocol help when asking:
- Scope 1 - your own emissions (combustion on site)
- Scope 2 - the energy you buy (electricity, heat)
- Scope 3 - everything upstream along the supply chain (often 70 per cent and more of the total footprint)
Your suppliers usually have Scope 1 under control, Scope 2 is manageable. Scope 3 is the real problem - because your Scope 3 is their Scope 1+2. That cascades up the chain.
Pragmatic recommendation
If you are now considering which method to choose:
- construction products: the Annex II characteristics through the Commission’s software; an existing EPD supplies most of the data for it
- batteries: PEF as a working assumption until the act under Art. 7 settles the method
- textiles, electronics, furniture: PEF as a working hypothesis, with an eye on the delegated regulation for your product category
- everything else: ISO 14044 as a basis and, if needed, switch to PEF or EPD
What you should avoid: a home-grown method that afterwards does not align with the ESPR format. That produces duplicate work.
Which carbon-footprint duty applies to your product group, and from when, is on its page in our industries reference.
Questions on this article
Which method does the ESPR require for our product?
That depends on the product group, and in most cases the delegated act for that group settles it. The ESPR builds on the Product Environmental Footprint, so PEF with the category rules for your product is the safe working assumption for textiles, electronics and furniture. Batteries follow their own act under Art. 7 of the Batteries Regulation. Construction is the exception, because Regulation (EU) 2024/3110 works with the environmental essential characteristics of Annex II, calculated with software the Commission provides free of charge (Art. 15(2)).
Does the carbon footprint have to be in a battery passport in February 2027?
No. The Commission guidance of July 2026 places the carbon footprint declaration and its label among the points not to be displayed at the start, because the act settling calculation and format is still missing. The duty then arrives in stages under Art. 7 - the declaration first, then the performance class, finally a maximum threshold, each 12 to 18 months after the respective act. Building calculation machinery before the act lands is still over-investing. The day-one list is in what is mandatory from February 2027.
Does an EPD count for a construction passport?
It helps, but it is not what the regulation asks for. EN 15804 appears only in the recitals of the Construction Products Regulation, as the source of characterisation factors for the Commission’s calculation software; the operative duty is the Annex II characteristics declared over the life cycle (Art. 15(2)). If you already hold EPDs, their underlying data carries most of Annex II. If you do not, plan for the Commission route rather than commissioning EPDs to satisfy a duty that is not written that way. More in the DPP for construction products.
What does a full study cost and how long is it good for?
An ISO-compliant study by an accredited consultancy typically runs 10,000 to 50,000 euros per product and stays valid for three to five years before it has to be updated. That is the reason to settle the method before commissioning the study, because a figure calculated to a scheme the act does not recognise has to be paid for twice.
Can we start with cradle-to-gate and extend later?
Yes, as an internal instrument. Multiplying material weights by factors from an aggregated life-cycle database is enough to find your hotspots and to make decisions about materials, and it costs a fraction of a full study. It is not enough for mandatory reporting, and the extension is not free either, because a wider system boundary needs the use phase and the end of life, which is new data rather than a longer calculation.
Our suppliers have no life-cycle data. What now?
That is the normal starting point and the reason to ask now. Between 70 and 85 per cent of an end product’s footprint comes from suppliers, and the typical lead time to actual data provision in a business relationship is 9 to 18 months. Ask your top ten suppliers for Scope 1 and Scope 2 figures first, because your Scope 3 is their Scope 1 and 2, and that cascades up the chain. Where a value is still missing, record what you have and note where it came from, rather than inventing a placeholder.
Which figure does the passport display, and in what unit?
The unit comes from the product group, not from the calculation. Batteries state CO2eq per kWh of battery capacity over the lifecycle, construction products state the Annex II characteristics over the life cycle, and the textile draft works per kilogram of textile product. A figure per item is rarely comparable, because product sizes vary, which is why every scheme relates it to a functional unit.
What happens when the method changes after we have published?
You publish a new version rather than editing the old one. Every Transpareo passport version is signed and the earlier states stay retrievable, so a recalculation under a new act is visible as a dated change instead of a value that quietly moved. The carbon fields are in the passport from the start, empty until the method for your group is settled.
